International Taxation
Today's global businesses demand a global approach to managing
their worldwide tax position which extends beyond the tax laws of a
single country.
From establishing the right structure of subsidiary companies and
branches and formulating global funding arrangements, to planning
for the repatriation of profits and using double tax treaties to
minimise withholding taxes on cross border currency flows, the
financial benefits from getting the approach right can be
tremendous. The penalty for getting it wrong is an unwanted
increase in a group's global tax charge.
Our worldwide tax experts understand how domestic and overseas tax
systems interact and take a co-ordinating role in managing clients'
worldwide tax affairs. Some of the areas in which our member firms
can help you maximise post-tax global profits include advising
on:
- Setting up global and regional holding companies
- Putting in place tax efficient international structures to
minimise withholding taxes on intra-group dividends and interest
payments
- Structuring loan finance to maximise tax relief for global
interest costs
- Packaging intellectual property rights into a dedicated vehicle
in an appropriate location and setting up intra-group licensing
arrangements
- Setting group pricing policies for goods and services in a
manner which avoids potentially expensive transfer pricing
challenges by national tax authorities
- Cross border mergers and acquisitions.